Sanctions database

EU Member States may authorise vessels that have changed their Russian flag or their registration, to the flag or register of any other state prior to 16 April 2022, to access a port or lock if (1) a Russian flag or registration was required by contract and (2) the access is necessary for the unloading of goods strictly necessary for the completion of renewable energy projects in the EU, provided that the import of such goods is not otherwise prohibited under Council Regulation (EU) No. 833/2014 (as amended).
Member States may authorise access for a vessel under certain specific circumstances, including in relation to the purchase, import or transport into the EU of (a) natural gas and oil, including refined petroleum products, and certain metals (titanium, aluminium, copper, nickel, palladium and iron ore), chemical and iron products (as listed in Annex XXIV to the EU Regulation), (b) pharmaceutical, medical, agricultural and food products, including wheat and fertilisers whose import, purchase and transport is allowed under this Regulation, (c) for humanitarian purposes, (d) nuclear fuel and other goods strictly necessary for the functioning of civil nuclear capabilities, (e) until 10 August 2022, coal and solid fossil fuels (as listed in Annex XXII
(e) the purchase, import or transport into the Union of coal and other solid fossil fuels, until 10 August 2022).

Prohibition does not apply to the provision of services that are (1) strictly necessary for the exercise of the right of defence in judicial proceedings and the right to an effective legal remedy, (2) strictly necessary to ensure access to judicial, administrative or arbitral proceedings in an EU Member State, or for the recognition or enforcement of a judgment or an arbitration award rendered in an EU Member State, provided that such provision of services is consistent with the objectives of the EU sanctions against Russia, or (3) ntended for the exclusive use of legal persons, entities or bodies established in Russia that are owned by, or solely or jointly controlled by, a legal person, entity or body which is incorporated or constituted under the law of a Member State, a country member of the European Economic Area, of Switzerland, the US, Japan, the UK or South Korea (so-called “partner countries”) (supplemented on 6 October 2022).
The competent authorities may authorise the services referred to therein, under such conditions as they deem appropriate, after having determined that this is necessary for: (a) humanitarian purposes, such as delivering or facilitating the delivery of assistance, including medical supplies, food, or the transfer of humanitarian workers and related assistance or for evacuations; (b) civil society activities that directly promote democracy, human rights or the rule of law in Russia, (c) the functioning of diplomatic and consular representations of the EU and of the EU Member States or partner countries in Russia, (d) ensuring critical energy supply within the EU and the purchase, import or transport into the EU of titanium, aluminium, copper, nickel, palladium and iron ore, (e) ensuring the continuous operation of infrastructures, hardware and software which are critical for human health and safety, or the safety of the environment, (6) the establishment, operation, maintenance, fuel supply and retreatment and safety of civil nuclear capabilities, and the continuation of design, construction and commissioning required for the completion of civil nuclear facilities, the supply of precursor material for the production of medical radioisotopes and similar medical applications, or critical technology for environmental radiation monitoring, as well as for civil nuclear cooperation, in particular in the field of research and development, or (f) the provision of electronic communication services by EU telecommunication operators necessary for the operation, maintenance and security, including cybersecurity, of electronic communication services, in Russia, in Ukraine, in the EU, between Russia and the EU, and between Ukraine and the EU, and for data centre services in the EU.

The EU Energy Ban features transitory periods for preexisting contracts and other exceptions. For contracts concluded before June 4, 2022, EU persons may continue conducting the following transactions, provided that the relevant Member State satisfies EU notification requirements:

*** A temporary exception is foreseen for imports of CN 2709 00 crude oil by pipeline into those EU member states that, due to their geographic situation, suffer from a specific dependence on Russian supplies and have no viable alternative options.
Bulgaria will also benefit from temporary derogations concerning the import of Russian seaborne crude oil.
Temporary derogations allowing the importation of seaborne crude oil are also available to landlocked Member States whose supply of crude oil by pipeline is interrupted for reasons outside of the Member State’s control.
The EU measure contains specific derogations for the Czech Republic, Bulgaria, and Croatia.
The ban does not apply to seaborne crude oil originating from third countries but are loaded in, depart from, or transit through Russia, provided that the origin and owner of the products are non-Russian.

For seaborne crude oil, spot market transactions and execution of existing contracts will be permitted for 6 months after entry into force.
Member States who have a particular pipeline dependency on Russia can benefit from a temporary exemption and continue to receive crude oil delivered by pipeline, until the Council decides otherwise. However, Member States benefiting from this exemption will not be able to resell such crude oil and petroleum products to other Member States or third countries.

Due to its specific geographical exposure, a special temporary derogation until the end of 2024 has been agreed for Bulgaria which will be able to continue to import crude oil and petroleum products via maritime transport. Croatia will be able to authorise until the end of 2023 the import of Russian vacuum gas oil which is needed for the functioning of its refinery.

Croatia will benefit from temporary derogations concerning the import of Russian seaborne vacuum gas oil.
The ban does not apply to petroleum products originating from third countries but are loaded in, depart from, or transit through Russia, provided that the origin and owner of the products are non-Russian.

*** For petroleum products, spot market transactions and execution of existing contracts will be permitted for 8 months after entry into force.

All exemptions to energy sanctions of the 6th package apply to insurance. If an operator can rely on any of the exceptions, then an insurer subject to EU jurisdiction can also provide insurance for such voyage, subject to applicable terms and conditions, as insurance would be deemed as being a necessary ancillary contract.